Innovate Finance has submitted its response to the Competition and Markets Authority's (CMA's) provisional decision on the Strategic Review of CMA Markets Remedies, opposing the proposed removal of Part 3 of the Retail Banking Market Investigation Order 2017.

Part 3 requires banks and building societies to commission independent customer surveys and publish comparable, standardised "league tables" on service quality for personal and business current accounts. This is one of the only publicly available, independently verified tools that allow consumers and SMEs to compare providers on quality rather than on brand or inertia.

Our response sets out why the CMA should retain Part 3 in full:

• Removal would disproportionately harm challenger banks. Digital-first and digital-only providers consistently rank at or near the top of Service Quality Indicator (SQI) results, without the brand recognition, legacy distribution and marketing budgets of the CMA9. Removing Part 3 would strip away the mechanism that converts better service into visible competitive advantage, entrenching incumbents rather than levelling the playing field.
• No demonstrated change of circumstances. The retail banking market remains highly concentrated and switching remains structurally low, including in the SME banking segment. The conditions that justified the remedy in 2016/17 persist.
• The FCA's Consumer Duty does not replace Part 3. Consumer Duty is a firm-level, principles-based obligation. It does not require standardised, comparable, cross-provider data, and does not produce a public league table. It has a fundamentally different function from Part 3's market-wide comparability.

We recommend that the CMA retain Part 3 in full. If the CMA proceeds with removal regardless, it should first publish the specific evidence underpinning its change-of-circumstances finding and consult further on the impact to challenger and digital-only providers.

Read our full response here